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  • canpolat.jpg
    Changes to Advance Tax Ruling System
    Burcu Canpolat Günes Avsar The need for a fertile flow of information between tax administration and taxpayers is vital for a well functioning fiscal system. The tax administration can utilise several different legal instruments for this purpose and an advance tax ruling system is one of those instruments. It is especially important if the tax system is based on a self-assessment system like Turkey.
    June 30 2010
  • edward.jpg
    FATCA update: New annual PFIC reporting rules/guidance on definitions and scope under Chapter 4 withholding
    Edward Tanenbaum Tola Ozim On April 6 2010, the Internal Revenue Service (IRS) released an advance copy of Notice 2010-34, which provides guidance pursuant to the recently enacted Section 1298(f) concerning the annual reporting requirements of US persons who are shareholders of a passive foreign investment company (PFIC).
    June 30 2010
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    Transaction tax does not fall within scope of merger directive
    Suzanne Boers The Dutch Supreme Court has referred an important preliminary question to the European Court of Justice (ECJ), regarding the interpretation of the merger directive. On May 20 2010 the ECJ gave its decision on this issue.
    June 30 2010
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    Investment opportunities between Bulgaria and Germany
    Rossitza Koleva Sophie Stylianou A wide range of double tax treaties have been concluded by Bulgaria in an attempt to strengthen the country's ties internationally and achieve a higher foreign direct investment rate in the country. Equally, existing treaties have been revised allowing for more attractive tax rates with respect to specific income deriving from either one of the participating states.
    June 30 2010
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    Tax treatment of loans in Montenegro
    Sead Dado Salkovic The peculiarity of the approach of the Montenegrin authorities with regard to the treatment of loans between related companies and especially loans extended by a non-resident parent company to a Montenegrin subsidiary do limit the means available for intra group financing and/or injection of equity at the subsidiary's level in order to initiate its investment activities.
    June 30 2010
  • Miller & Chevalier hires Robert Kirschenbaum
    Robert Kirschenbaum has moved from Baker & McKenzie to join Miller & Chevalier Chartered in Washington, DC.
    June 30 2010
  • Discriminatory withholding tax on dividends in Europe under fire
    The success of a Dutch pension fund in securing repayments of dividend withholding tax from authorities augurs well for claimants both in and outside of the EU, says Daniël Smit of Ernst & Young in the Netherlands.
    June 29 2010
  • brazil-congress-tiny.jpg
    Non-conversion of executive measure into law causes problems in Brazil
    Cristiane Magalhães and Daniel Orsini Marcondes of Machado Associados Advogados e Consultores explain what the failure of MP 478 to become firm law will mean for taxpayers in Brazil.
    June 29 2010
  • Patton leaves Ernst & Young
    After 21 years with Ernst & Young, Mike Patton is leaving the firm to join DLA Piper.
    June 29 2010
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    Australian judge sets aside OECD guidelines
    An Australian company has won an important decision in the Federal Court over use of the comparable uncontrolled price (CUP) method when a distributor purchases from associated offshore manufacturing entities.
    June 29 2010
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